Irs Move Takes Toll On Comdisco

Comdisco Inc. stock lost about one-fourth of its value Friday after the company disclosed it is contesting in U.S. Tax Court $200 million in proposed Internal Revenue Service assessments.

This is the second time in recent years that the Rosemont computer leasing firm has come under IRS scrutiny. Comdisco said it believed the proposed assessments were unjustified and would have ``no material effect`` on the firm.

Comidisco`s stock plummeted 24 percent on the New York Stock Exchange in heavy trading Friday, closing down $6.50 a share at $20.37.

The IRS action covers the years 1980 through 1982 and contends that the proceeds or principal amount from Comdisco`s equipment borrowing is taxable income.

``That ($200 million) is more that we ever made in those years in pretax income,`` said Michael Brown, executive vice president.

He explained that Comdisco operates like other leasing companies in that it takes lease receivables to the bank and borrows against them. ``The IRS is saying that when we borrow $80 against $100 (in receivables), the entire $80 should be included as income right then,`` he said.

The IRS position on this issue, which covers about 95 percent of the proposed adjustments, is ``directly contrary to Comdisco`s, and the entire leasing industry`s, normal practice of financing equipment by discounting lease receivables,`` added Chairman Kenneth N. Pontikes.

The company additionally pointed out that this practice is supported by a series of federal court decisions and also many rulings by the IRS` own national office regarding leveraged lease transactions.

In early 1984, the IRS conducted an audit of Comdisco for alleged abusive tax shelters.

In May, 1984, Comdisco reported that the IRS had advised the company that it had discontinued its review without taking any action adverse to it.